The DOL issued a Field Assistance Bulletin addressing both a situation in which the final rule delaying the prior fiduciary rules is not issued before April 10, 2017 when those rules take effect and a situation in which the DOL decides not to delay the April 10th date.
DOL will not take enforcement actions for noncompliance with the prior fiduciary rules during the “gap” period between April 10 and when the final rule implementing the delay takes effect or, in the event that no delay is implemented, during the period between April 10 and a “reasonable period after the publication of a decision not to delay the April 10 applicability date.”
